On August 19, 2019, the Centers for Medicare and Medicaid Services (“CMS”) announced plans for two updates to its Overall Hospital Quality Star Ratings (“Star Ratings”). The first, in early 2020, to “refresh” the Star Ratings using the current methodology and the second, in 2021, to update the quality measurement methodology of the Star Ratings on CMS’s Hospital Compare website. The Star Ratings rate hospitals on a quality scale of one to five, summarizing a variety of measures reflecting common conditions hospitals treat. According to CMS Administrator Seema Verma, the goal of the changes is to empower patients to “make informed health care decisions, leading providers to compete on the basis of cost and quality.”

CMS originally sought comments on possible changes to the Star Ratings methodology in February 2019, proposing a number of potential modifications. In the August 19 announcement, CMS highlights comments from that public comment period that characterized the Star Ratings as overly complex, not specific enough, or as oversimplifying quality measurement and that recommended making the ratings more precise and allowing more direct “apples-to-apples” comparisons, stating that these would inform the methodology CMS ultimately plans to propose.

However, not all stakeholders feel these proposed changes will adequately address the “substantial flaws” that many providers and organizations, like the American Hospital Association (“AHA”), see in CMS’s Star Rating system methodology. The AHA submitted a detailed letter in response to CMS’s request for public comment, asserting that most of CMS’s proposals either failed to “address important shortcomings with star ratings,” or did “not have enough information” to permit evaluation of their impact. There were three CMS proposals – empirical criteria for measure groups, peer grouping star ratings among similar hospitals, and using an explicit scoring approach – the AHA did believe CMS should pursue, and the AHA also recommended three areas of “additional considerations” to address before implementing any changes.

CMS plans more public outreach on the methodology changes, including a public listening session on September 19, 2019.